FAC Explorer

Finding 49956 (2022-003)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-06-28
Audit: 46560
Organization: Population Services International (DC)
Auditor: Bdo

AI Summary

  • Core Issue: PSI's monitoring of its subrecipient did not comply with federal audit requirements, specifically 2 CFR 200, Subpart F, as the subrecipient's audit was not conducted properly.
  • Impacted Requirements: The failure to adhere to internal control policies can lead to noncompliance with federal regulations, risking disallowed costs for the federal program.
  • Recommended Follow-Up: PSI should enhance documentation practices to capture management's assessments of subrecipient compliance and provide training on audit requirements for foreign-based subrecipients.

Finding Text

2022-003 Internal Control over Compliance with Subrecipient Monitoring Requirements See Schedule of Findings and Questioned Costs for chart/table Criteria or Specific Requirement: ?200.303 Internal Controls states that a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During the audit, we tested PSI?s monitoring of the only subrecipient within the major program AL# 93.067. We noted that PSI has documented policies and procedures in addition to a multitude of tools to comply with the subrecipient monitoring process. However, in the single sample tested, PSI obtained the statutory audit report from the subrecipient and reviewed the contents of that audit report. However, the subrecipient?s audit was not performed in accordance with 2 CFR 200, Subpart F. The Centers for Disease Control and Prevention (CDC) mandates a foreign-based subrecipient is required to conduct a single audit or program specific audit if expenditures are $300,000 or greater in a given fiscal year. The subrecipient?s statutory report did not comply with the CDC guidelines. PSI management provided email communication between PSI and the subrecipient inquiring about the need for an audit in accordance with 2 CFR 200, Subpart F; however, the email documentation did not document PSI management?s considerations and conclusions regarding the fact that the subrecipient had a statutory audit performed, instead of an audit in accordance with 2 CFR 200, Subpart F. Questioned Costs: There are no questioned costs. Context: This is a condition identified based on our review of the internal control documentation used to support the monitoring of the subrecipient selected for testing. No sampling was required as there was only one subrecipient for the major program AL# 93.067. Cause: PSI?s subrecipient monitoring policies and procedures contain requirements for PSI to obtain subrecipient audit reports and review those reports. However, based on the matter identified, the policies and procedures do not contain adequate guidance to address a subrecipient?s noncompliance with the audit requirements of 2 CFR 200, Subpart F. Effect: The lack of adherence to the established internal control policies and procedures can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: BDO recommends that PSI implement specific documentation requirements related to PSI management?s considerations and conclusions regarding subrecipient noncompliance with a particular federal statue or condition of an award. While PSI?s procedures may address risk associated with subrecipient noncompliance, the maintenance of written documentation to evidence considerations and conclusions is imperative to PSI?s risk management process. Views of Responsible Officials: PSI management agrees with the finding and recommendations set forth within and will work with program management teams to provide guidance and training related to non-U.S. subrecipient organization audit requirements. Refer to management?s corrective action plan for additional information.

Corrective Action Plan

2022-003 Internal Control over Compliance with Subrecipient Monitoring Requirements Contact: Karen Conley Title: Director, Grants & Contracts, Program Ethics Phone Number: 202-549-8388 Estimated Completion Date ? ongoing Corrective Action Grants and Contracts will work closely with the Program Management teams to remind non-US subrecipient organizations of the US government funding requirements included in their sub agreements and their need to comply with the annual audit certification letters. Following a departmental re-organization, the Subaward Compliance Unit in the Grants and Contracts Department will focus on strengthening PSI?s SR monitoring process.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 39494 2022-005
    Significant Deficiency Repeat
  • 39495 2022-005
    Significant Deficiency Repeat
  • 39496 2022-005
    Significant Deficiency Repeat
  • 39497 2022-001
    Significant Deficiency Repeat
  • 39498 2022-005
    Significant Deficiency Repeat
  • 49946 2022-002
    Significant Deficiency Repeat
  • 49947 2022-005
    Significant Deficiency Repeat
  • 49948 2022-002
    Significant Deficiency Repeat
  • 49949 2022-005
    Significant Deficiency Repeat
  • 49950 2022-002
    Significant Deficiency Repeat
  • 49951 2022-004
    Significant Deficiency
  • 49952 2022-005
    Significant Deficiency Repeat
  • 49953 2022-006
    Significant Deficiency Repeat
  • 49954 2022-002
    Significant Deficiency Repeat
  • 49955 2022-001
    Significant Deficiency Repeat
  • 49957 2022-001
    Significant Deficiency Repeat
  • 49958 2022-004
    Significant Deficiency
  • 615936 2022-005
    Significant Deficiency Repeat
  • 615937 2022-005
    Significant Deficiency Repeat
  • 615938 2022-005
    Significant Deficiency Repeat
  • 615939 2022-001
    Significant Deficiency Repeat
  • 615940 2022-005
    Significant Deficiency Repeat
  • 626388 2022-002
    Significant Deficiency Repeat
  • 626389 2022-005
    Significant Deficiency Repeat
  • 626390 2022-002
    Significant Deficiency Repeat
  • 626391 2022-005
    Significant Deficiency Repeat
  • 626392 2022-002
    Significant Deficiency Repeat
  • 626393 2022-004
    Significant Deficiency
  • 626394 2022-005
    Significant Deficiency Repeat
  • 626395 2022-006
    Significant Deficiency Repeat
  • 626396 2022-002
    Significant Deficiency Repeat
  • 626397 2022-001
    Significant Deficiency Repeat
  • 626398 2022-003
    Significant Deficiency
  • 626399 2022-001
    Significant Deficiency Repeat
  • 626400 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
98.U00 Advancing Progress in Malaria Service Delivery $41.67M
98.001 Going the Last Mile for Hiv Control $20.40M
98.001 Momentum Targeted Mnch/fp/rh Technical Assistance to Private Providers $19.95M
98.001 Angola Health for All $11.66M
98.001 Improving Market Partnerships and Access to Commodities Together (impact) $10.87M
98.001 Donated Commodities $8.26M
98.U00 Donated Commodities $6.73M
93.067 Provision of Voluntary Medical Male Circumcision (vmmc) for Hiv Prevention in the Republic of South Africa Under the President's Emergency Plan for Aids Relief (pepfar) $6.70M
98.U00 Global Health Supply Chain (gshc) - Procurement and Supply Management (psm) $6.09M
98.001 Ethiopia Transform: Water, Sanitation and Hygiene $5.73M
98.001 Stop Djekoidjo $4.34M
98.001 Hiv Services for Key and Priority Populations $4.33M
98.001 Covid-19 - Angola Health for All $3.94M
98.001 Expanding Malawi Hiv-Aids Prevention with Local Organizations Working for An Effective Epidemic Response (empower) $3.82M
98.U00 Vector Control Indefinite Delivery Indefinite Quantity Contract (vc Idiq", Project") $3.53M
98.001 Cambodia Promoting Healthy Behaviors Activity $3.50M
98.001 Samagra: A Total Market for Comprehensive Consumer-Empowered Primary Health $3.16M
93.067 Scaling Up Targeted Hiv Testing Services and Linkage to Treatment $2.94M
98.001 Covid -19 - Going the Last Mile for Hiv Control $2.83M
12.350 Cdi Dhapp Faci Partnership for Sustainable Hiv Epidemic Control $2.66M
93.067 Improving Hiv/sti/tb Prevention, Treatment and Care Services for Mobile Populations $2.36M
93.067 Strategic Scale Up of Community Based Hiv Testing and Counseling $2.33M
12.350 Burundi National Defense Force (bndf) Partnership for Sustainable Hiv Epidemic Control $2.13M
98.001 Tubiteho $1.93M
98.001 Tb/hiv Agency, Information and Services $1.65M
98.001 Covid -19 - Meeting Targets and Maintaining Epidemic Control (epic) $1.56M
98.001 Enhancing Quality of Healthcare Activity $1.31M
98.001 Improved Family Planning Initiative $1.13M
98.001 Evaluation Innovative Technologies and Approaches to Addressing Cervical Cancer in the Republic of Mozambique $1.04M
98.001 Hiv Prevention for High Risk Individuals $1.04M
98.001 Madagascar's Accessible Continuum of Care and Essential Services Sustained (access) $902,728
98.001 Countywide Sanitation Activity (cwsa) $725,677
98.001 Myanmar Essential Health Services Program $706,979
98.001 Expanding Contraception $664,246
12.350 Lesotho-Military Specific Hiv/aids Prevention, Care, and Treatment Program for Pepfar Funded Countries $606,476
98.001 Tanzania Malaria Case Management Activity $578,095
98.001 Mozambique Small Town Sanitation Project $525,474
98.001 The Kampala Slum Maternal Newborn Project: Innovating for Better Systems Outcomes $441,658
12.350 Central America Regional Partnership for Sustainable Hiv Epidemic Control in the Guatemalan, Honduran and Salvadoran Militaries $423,396
98.U00 Usaid West Africa Municipal Wash (muniwash) $405,921
98.001 Research for Scalable Solutions (r4s) $381,148
93.067 Recent Infection Surveillance Consortium $341,069
98.001 Covid -19 - Path and the Digital Health Initiative - Accelerating the Cycle for Investment $332,189
98.U00 Usaid Western Kenya Sanitation Project (wksp) $310,541
98.001 Covid - 19 - Expanding Malawi Hiv-Aids Prevention with Local Organizations Working for An Effective Epidemic Response (empower) $290,891
98.001 Covid-19 - Samagra: A Total Market for Comprehensive Consumer-Empowered Primary Health $265,928
93.067 Donated Commodities $232,586
98.001 Covid - 19 - Hiv Services for Key and Priority Populations $228,607
98.U00 Covid -19 - Advancing Progress in Malaria Service Delivery $219,882
98.001 Unaids in Support of the Unified Budget and Workplace $198,671
98.001 Digital Health Initiative Accelerating the Cycle of Investment to Impact in Global Digital Health $197,669
98.001 Next Generation Products for Prevention of Hiv Infection in Women (nix Hiv) $148,796
98.001 Health and Hygiene Project $117,889
12.350 Advancing Multi-Country Hiv Support in Collaboration with Dhapp and Partner Militaries for Sustainable Hiv Epidemic Control (multi-Country) $114,693
98.001 Covid - 19 - American Rescue Plan Act (arpa) Covid-19 Support $71,062
93.318 Covid-19 Vaccination Program Support in Eswatini $70,386
98.001 Covid -19 - Ethiopia Transform: Water, Sanitation and Hygiene $52,331
98.001 Usaid Hiv Prevention, Testing and Treatment Services for Key Populations $48,592
98.001 Growth Through Nutrition $41,861
98.001 Bangladesh Marketing Innovations for Sustainable Health Development $41,091
93.067 Covid-19 - Improving Hiv/sti/tb Prevention, Treatment and Care Services for Mobile Populations $40,372
93.067 Covid - 19 - Strategic Scale Up of Community Based Hiv Testing and Counseling $32,282
98.001 Covid -19 - Research for Scalable Solutions (r4s) $7,738
98.001 High Impact Maternal, Newborn and Child Health (hi-Mnch) Activity $3,767
98.001 Family Planning Integrated Project $-5
12.350 Hiv/aids Prevention, Care and Treatment Support to the South African National Defense Force $-42
98.001 Meeting Targets and Maintaining Epidemic Control (epic) $-107
19.703 Costa Rica - Building Capacity to Prevent and Address Domestic Violence $-161
93.067 Covid -19 - Scaling Up Targeted Hiv Testing Services and Linkage to Treatment $-279
93.067 Programmatic Implementation and Technical Assistance (ta) for Hiv/aids $-702
98.001 Sustaining Health Outcomes Through the Private Sector Project Plus (shops Plus) $-874
93.067 Accelerating Epidemic Control in 7 Districts of Mubende Region in the Republic of Uganda Under the President's Emergency Plan for Aids Relief (pepfar) $-1,981
98.001 Zimbabwe Strengthening Private Sector Services Project $-962,286